As the Commonwealth Coordinated Care (CCC) program continues its expansion across the five demonstration regions, residents and nursing facility personnel in those regions begin dealing with an array of issues associated with the new program. Many issues have been identified, as have approaches to minimize their impact. In order to facilitate the discussion of solutions with the Department of Medical Assistance Services (DMAS) to the array of issues with CCC, it is imperative that VHCA be made aware of the on-the-ground issues you experience with CCC. To this end, VHCA developed the CCC Issue Log, which is available publicly (no member log-in required) on our website, www.vhca.org, under “News & Events” on the right hand side of the homepage.

Please consider sharing this link with your frontline staff (both indirect and direct care staff) for input on all aspects of the CCC program.

To date, issues identified have been:

Access to enrollment data: DMAS has made available a report, called the 270/271, that allows for batch queries of eligibility status, including enrollment status with CCC. However, facilities and their IT staff/venders have had difficulty accessing the data in a useable format, with staff generally reverting to the existing Medi-Call/ARS system, with limited batch query capability. VHCA and DMAS are currently engaged in identifying an interim solution to get nursing facilities the CCC enrollment data they need. While a solution is not yet available, we are optimistic one will be found. However, we encourage folks to continue working to get access to the 270/271 report, as this is the long term solution from the DMAS perspective.

Primary care physician assignment and ancillary providers: Under CCC, the MMPs assign a primary care physician (PCP) to each participant. The PCP is not only a primary care-giver for physician services, but is also the gateway, so-to-speak, for certain other services in terms of making referrals. The experience with CCC in Tidewater identified that, for participating nursing facility residents, PCP assignment did not always align with the existing team of providers caring for the residents. This poses problems in terms of continuity of care, but also in terms of nursing facility credentialing of physicians delivering care in their facility (an issue for other MMP-networked ancillary providers as well). To make matters worse, it was not evident that the PCPs assigned even understood and acknowledged the unique needs of caring for a nursing facility resident, such as routine facility visits (as opposed to office visits) and 24/7 referral response. VHCA and DMAS are in the process of developing criteria to minimize this misalignment, which includes encouraging your ancillary providers to enroll in MMP networks (see reprinted article, “Consider Sending Your Provider Lists to the MMPS”).

CCC-participating residents in facilities that are not in or not yet active in CCC: Questions from the field have emerged regarding why a nursing facility in a region that is either not in the CCC demonstration area or that is not yet active for passive (automatic) enrollment have experienced an influx of CCC-participation among residents. In working with DMAS, VHCA has come to understand that the eligibility status for an individual in terms of the CCC program depends on the locality in which the Department of Social Services (DSS) maintains the Medicaid case. Medicaid eligibility policy dictates that the local DSS where the individual lived prior to entry in a nursing facility is responsible for on-going case-maintenance, even if the resident’s placement is a nursing facility located outside of that jurisdiction. This means that residents in facilities outside of Tidewater, for example, may have been automatically enrolled and be active for coverage in CCC because their case originated and continues to be maintained in a Tidewater DSS. Thus, nursing facilities who did not think they needed to be concerned with CCC issues, either at all or as yet, may in fact be impacted, particularly as passive enrollment expands across the demonstration (see attached chart for current locality status, including dates of passive enrollment). [link to same pdf from previous article]

Again, please continue to use the CCC Issue log to inform VHCA and subsequently, your colleagues regarding issues identified with the CCC program. This tool is integral in our ability at VHCA to work with DMAS toward solutions.